Air Force Officials Did Not Consistently Comply With Requirements for Assessing Contractor Performance

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1 Inspector General U.S. Department of Defense Report No. DODIG JANUARY 29, 2016 Air Force Officials Did Not Consistently Comply With Requirements for Assessing Contractor Performance INTEGRITY EFFICIENCY ACCOUNTABILITY EXCELLENCE

2 INTEGRITY EFFICIENCY ACCOUNTABILITY EXCELLENCE Mission Our mission is to provide independent, relevant, and timely oversight of the Department of Defense that supports the warfighter; promotes accountability, integrity, and efficiency; advises the Secretary of Defense and Congress; and informs the public. Vision Our vision is to be a model oversight organization in the Federal Government by leading change, speaking truth, and promoting excellence a diverse organization, working together as one professional team, recognized as leaders in our field. Fraud, Waste & Abuse HOTLINE Department of Defense dodig.mil/hotline For more information about whistleblower protection, please see the inside back cover.

3 Results in Brief Air Force Officials Did Not Consistently Comply With Requirements for Assessing Contractor Performance January 29, 2016 Objective We determined whether Air Force officials completed comprehensive and timely contractor performance assessment reports (PARs) for nonsystems contracts as required by Federal and DoD policies. The purpose of a PAR is to provide source selection officials with information on contractor past performance. This is the second in a series of audits of DoD compliance with policies for evaluating contractor performance. We selected a nonstatistical sample of four commands that prepared 48 PARs with a contract value of $2.4 billion. Finding Air Force Life Cycle Management Center (AFLCMC); Headquarters Space and Missile Systems Center (HQ SMC); Air Combat Command, Acquisition Management Integration Center (ACC AMIC); and 338th Specialized Contracting Squadron (SCONS) officials did not consistently comply with requirements for evaluating contractor past performance when preparing 48 PARs. Specifically, HQ SMC and ACC AMIC assessors did not prepare 7 of 48 PARs within the 120 day required timeframe. In addition, Air Force officials at all four commands prepared 37 of 48 PARs without sufficient written narratives to justify the ratings given or without sufficient descriptions of the contract purpose. These conditions occurred because: Air Force command-specific procedures did not consistently ensure timeliness or did not address timeliness; assessors did not understand PAR rating definitions or evaluation factors; Visit us at Finding (cont d) assessors did not take, or properly implement, training; or Air Force officials did not consistently perform adequate reviews of the written narrative. AFLCMC, HQ SMC, and 338th SCONS did not have written procedures to register contracts; however, Air Force officials properly registered or had a valid reason for not registering 161 contracts. Written procedures are necessary to ensure continued compliance with registration requirements. As a result, Federal Government source selection officials did not have access to timely, accurate, and complete contractor performance assessment information needed to make informed decisions related to contract awards or other acquisition matters. Recommendations We recommend that the Commanders of AFLCMC, HQ SMC, and 338th SCONS and the Director of ACC AMIC develop or improve procedures for preparing PARs within 120 days; ensuring assessors take initial and periodic refresher training for writing PARs; evaluating PARs for quality; or registering contracts. Management Comments and Our Response On behalf of AFLCMC, we received comments from the Senior Materiel Leader, AFLCMC Command and Control, Intelligence, Surveillance, and Reconnaissance (C2ISR) and the Deputy Chief, AFLCMC Medium Altitude Unmanned Aircraft Systems (MA UAS). We also received comments from the Commanders, HQ SMC and 338th SCONS, and the Deputy Director, ACC AMIC. The Commander, HQ SMC; Deputy Director, ACC AMIC; and Senior Materiel Leader, AFLCMC C2ISR addressed all specifics of the recommendations and no further comments are required. Comments from the Commander, 338th SCONS, and Deputy Chief, AFLCMC MA UAS did not address all specifics of the recommendations and we request that they provide comments on this report by February 28, Please see the Recommendations Table on the next page. DODIG (Project No. D2015-D000CF ) i

4 Recommendations Table Management Senior Materiel Leader, Air Force Life Cycle Management Center Command and Control, Intelligence, Surveillance, and Reconnaissance Deputy Chief, Air Force Life Cycle Management Center Medium Altitude Unmanned Aircraft Systems Recommendations Requiring Comment No Additional Comments Required 2.a, 2.b, 2.c, 2.d, 3 2.d 2.a, 2.b, 2.c, 3 Commander, Headquarters Space and Missile Systems Center 2.a, 2.b, 2.c, 2.d, 3 Deputy Director, Air Combat Command, Acquisition Management and Integration Center 1.a, 1.b, 1.c, 3 Commander, 338th Specialized Contracting Squadron 2.a, 2.b, 2.c, 2.d 3 Please provide Management Comments by February 28, ii DODIG (Project No. D2015-D000CF )

5 INSPECTOR GENERAL DEPARTMENT OF DEFENSE 4800 MARK CENTER DRIVE ALEXANDRIA, VIRGINIA MEMORANDUM FOR UNDER SECRETARY OF DEFENSE FOR ACQUISITION, TECHNOLOGY, AND LOGISTICS. ASSISTANT SECRETARY OF THE AIR FORCE (FINANCIAL MANAGEMENT AND COMPTROLLER) NAVAL INSPECTOR GENERAL January 29, 2016 SUBJECT: Air Force Officials Did Not Consistently Comply With Requirements for Assessing Contractor Performance (Report No. DODIG ) We are providing this report for review and comment. Air Force officials registered contracts in the Contractor Performance Assessment Reporting System, but they did not prepare 7 of 48 performance assessment reports in a timely manner and they did not provide sufficient written narratives to justify the ratings given, as required by the Federal Acquisition Regulation. We conducted this audit in accordance with generally accepted government auditing standards. We considered management comments on a draft of this report when preparing the final report. DoD Instruction requires that recommendations be resolved promptly. Comments from the Commander, Headquarters Space and Missile Systems Center; Deputy Director, Air Combat Command, Acquisition Management Integration Center; and Senior Materiel Leader, Air Force Life Cycle Management Center Command and Control, Intelligence, Surveillance, and Reconnaissance, fully addressed all specifics of the recommendations. Comments from the Commander, 338th Specialized Contracting Squadron addressed all specifics of Recommendation 3, partially addressed Recommendations 2.b and 2.d, but did not address Recommendations 2.a and 2.c. Comments from the Deputy Chief, Air Force Life Cycle Management Center Medium Altitude Unmanned Aircraft Systems, addressed all specifics of Recommendations 2.a, 2.b, and 2.c and partially addressed Recommendations 2.d and 3. Comments from the Deputy Chief, Air Force Life Cycle Management Center Medium Altitude Unmanned Aircraft Systems to Recommendation 3 met the intent of that recommendation and we will not request additional comments. Therefore, we request that the Commander, 338th Specialized Contracting Squadron, provide additional comments to Recommendations 2.a, 2.b, 2.c, and 2.d and the Deputy Chief, Air Force Life Cycle Management Center Medium Altitude Unmanned Aircraft Systems, provide additional comments to Recommendation 2.d by February 28, Please provide comments that conform to the requirements of DoD Instruction Please send a PDF file containing your comments to Copies of your comments must have the actual signature of the authorizing official for your organization. We cannot accept the /Signed/ symbol in place of the actual signature. If you arrange to send classified comments electronically, you must send them over the SECRET Internet Protocol Router Network (SIPRNET). We appreciate the courtesies extended to the staff. Please direct questions to me at (703) (DSN ). Michael J. Roark Assistant Inspector General Contract Management and Payments DODIG iii

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7 Contents Introduction Objective 1 Background 1 Audit Scope 4 Review of Internal Controls 5 Finding. Air Force Officials Compliance With Past Performance Reporting Requirements Needs Improvement 6 HQ SMC and ACC AMIC Assessors Prepared PARs Late, and Some Commands Did Not Have Procedures to Ensure Timeliness 7 Assessors Did Not Adequately Justify PAR Ratings 9 Air Force Officials Reviews of Written Narratives Did Not Consistently Identify Noncompliance With the FAR 15 Assessors Complied With Registration Requirements, but Written Procedures Needed 16 Air Force Officials Did Not Adequately Justify Past Performance With Readily Available Information 17 ACC AMIC Management Actions Taken 17 Management Comments on the Findings and Our Response 18 Recommendations, Management Comments, and Our Response 19 Appendixes Appendix A. Scope and Methodology 29 Universe and Sample 29 Documentation and Interviews 30 Criteria Reviewed 30 Use of Computer-Processed Data 31 Use of Technical Assistance 31 Prior Coverage 31 Appendix B. Improvement in PAR Completion Statistics 33 DODIG v

8 Contents (cont d) Appendix C. Summary of PARs Reviewed 37 Appendix D. Summary of Evaluation Factors Not Supported 40 Appendix E. PAR Rating Definitions 43 Management Comments Air Force Life Cycle Management Center Command and Control, Intelligence, Surveillance, and Reconnaissance 47 Air Force Life Cycle Management Center Medium Altitude Unmanned Aircraft Systems 52 Headquarters Space and Missile Systems Center 55 Air Combat Command, Acquisition Management and Integration Center th Specialized Contracting Squadron 59 Acronyms and Abbreviations 61 vi DODIG

9 Introduction Introduction Objective We determined whether Air Force officials completed comprehensive and timely contractor performance assessment reports (PARs) for nonsystems contracts 1 as required by Federal and DoD policies. This is the second in a series of audits of DoD compliance with policies for evaluating contractor performance. See Appendix A for a discussion of the scope, methodology, and prior coverage. Background Contractor Performance Assessment Reporting System and Past Performance Information Retrieval System The Contractor Performance Assessment Reporting System (CPARS) is a paperless contractor evaluation system. The primary purpose of CPARS is to ensure that current, complete, and accurate information on contractor performance is available for use in procurement source selections. The Federal Acquisition Regulation (FAR) 2 states that CPARS is the Government-wide reporting tool for all past performance reports on contracts. The FAR 3 also states that agencies must assign responsibility and accountability for the completeness of past performance submissions and that agency procedures must address management controls and appropriate management reviews of past performance evaluations to include accountability for documenting past performance. When officials submit a completed PAR, it automatically transfers to the Past Performance Information Retrieval System. Federal Government source selection officials obtain PARs from the Past Performance Information Retrieval System. The process begins when the Federal Procurement Data System-Next Generation 4 feeds contracts that exceed the reporting thresholds established by the FAR and Defense Federal Acquisition Regulation Supplement 5 into CPARS. CPARS classifies contracts into different business sectors and the Defense Federal Acquisition Includes contracts, task orders, and delivery orders. FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Policy, (a), General. FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Procedures. The Federal Procurement Data System-Next Generation is a web-based tool for agencies to report contract actions. FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Policy, (b), Contracts, requires officials to prepare evaluations of contractor performance for contracts that exceed the simplified acquisition threshold; however, the Defense Federal Acquisition Regulation Supplement deviates from the FAR and raises the reporting thresholds. See Table 1. DODIG

10 Introduction Regulation Supplement 6 establishes a specific dollar reporting threshold for each business sector. Table 1 identifies the CPARS business sectors and DoD s dollar reporting thresholds. Table 1. CPARS Business Sectors and DoD Reporting Thresholds Business Sector Dollar Threshold Systems > $5,000,000 Non-Systems Operations Support > $5,000,000 Services > $1,000,000 Information Technology > $1,000,000 Ship Repair and Overhaul > $500,000 Architect-Engineer $30,000 Construction $650,000 Officials access CPARS and review the contracts that the Federal Procurement Data System-Next Generation fed into the system. The officials determine whether they need to register the contract. 7 When officials register contracts in CPARS, they assign personnel to complete the assessment of the contractor, which is done by writing a PAR. Contracts may have one or more PARs prepared over the contract s period of performance. Because the FAR 8 requires assessors to prepare PARs at least annually and at the time the contractor completes the work, each contract should have at least one PAR for each year of the contract. Results of Previous DoD Office of the Inspector General Reports The DoD Office of the Inspector General (OIG) issued two previous reports addressing DoD officials preparation and use of contractor past performance information Defense Federal Acquisition Regulation Supplement Part 242, Contractor Performance Information, , Policy, states that past performance evaluation thresholds are contained in a DoD class deviation. The Under Secretary of Defense for Acquisition, Technology, and Logistics issued, Class Deviation Past Performance Evaluation Thresholds and Reporting Requirements, September 24, 2013, which identifies DoD s reporting thresholds for CPARS. The Guidance for the Contractor Performance Assessment Reporting System (CPARS), July 2014, allows officials to choose how they want to prepare PARs for indefinite-delivery contracts and the orders awarded against them. Officials may prepare PARs on the overall indefinite-delivery contract or on the individual orders. FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Policy, (a), General. 2 DODIG

11 Introduction FY 2015 DoD OIG Report DoD OIG issued Report No. DODIG , Navy Officials Did Not Consistently Comply With Requirements for Assessing Contractor Performance, on May 1, We reported that Navy officials did not consistently comply with requirements for evaluating contractor past performance when they registered contracts and prepared PARs. Specifically, the audit team reported that: 88 of 797 contracts were not registered, 42 of 81 PARs were prepared an average of 84 days late, and 61 of 81 PARs were prepared without sufficient written narratives to justify the ratings given. The report recommended that Navy officials develop or improve procedures for registering contracts, preparing PARs within the required timeframe, requiring initial and periodic refresher training for writing PARs, and evaluating PARs for quality. FY 2008 DoD OIG Report DoD OIG issued Report No. D , Contractor Past Performance Information, on February 29, The report stated that CPARS did not contain all active system contracts that met the reporting threshold of $5 million. In addition, the audit team reported that: 39 percent of system contracts were registered more than a year late; 68 percent of system contracts had PARs that were overdue; and 82 percent of PARs reviewed did not contain detailed, sufficient narratives to establish that ratings were credible and justifiable. The report recommended the Under Secretary of Defense for Acquisition, Technology, and Logistics (USD[AT&L]) establish a requirement to: register contracts in CPARS within 30 days from contract award, complete the annual PARs in CPARS within 120 days from the end of the evaluation period, and require formal training on writing PAR narratives and the corresponding ratings for the assessors who prepare and review PARs. In response to the report recommendations, USD(AT&L) issued a memorandum 9 that requires DoD officials to register contracts and complete PARs within 120 days. However, the memorandum did not require formal training for CPARS assessors, as recommended by the FY 2008 report. 9 USD(AT&L) memorandum, Past Performance Assessment Reporting, January 9, DODIG

12 Introduction Senate Armed Services Committee Request for Audit In a June 4, 2010, Senate Armed Services Committee report, 10 the Committee directed DoD OIG to perform a follow up audit to determine whether DoD officials improved compliance with past performance requirements and maintained a more complete and useful database of contractor past performance information. Appendix B shows that Air Force officials at the commands in our scope reduced the timeframes to prepare PARs from FY 2010 through FY 2015; therefore, Air Force officials compliance with past performance requirements improved. This is the second in a series of audits; the first audit, as previously discussed, reported on the Navy. 11 We reported on the Navy first because the Navy is the executive agent for CPARS. Audit Scope We selected a nonstatistical sample of four Air Force commands: Air Force Life Cycle Management Center (AFLCMC), Robins Air Force Base (AFB), Warner Robins, Georgia; Headquarters Space and Missile Systems Center (HQ SMC), Los Angeles AFB, El Segundo, California; Air Combat Command, Acquisition Management and Integration Center (ACC AMIC), Newport News, Virginia; and 338th Specialized Contracting Squadron (SCONS), Joint Base San Antonio Randolph, San Antonio, Texas. These four commands awarded a total of 161 contracts valued at $5.4 billion. We determined that assessors completed PARs for 58 of the 161 contracts, as of September 2, We reviewed 48 of the 58 PARs. The 48 PARs had a total contract value of $2.4 billion. See Appendix A for a complete discussion of our audit scope and methodology Senate Report , National Defense Authorization Act for Fiscal Year 2011, published June 4, DoD OIG Report No. DoDIG , Navy Officials Did Not Consistently Comply With Requirements For Assessing Contractor Performance, May 1, DODIG

13 Introduction Review of Internal Controls DoD Instruction , Managers Internal Control Program Procedures, May 30, 2013, requires DoD organizations to implement a comprehensive system of internal controls that provides reasonable assurance that programs are operating as intended, and to evaluate the effectiveness of the controls. We identified internal control weaknesses for the Air Force. Specifically, AFLCMC, HQ SMC, ACC AMIC, and 338th SCONS policies and procedures did not contain adequate controls to ensure assessors completed PARs within required timeframes or completed PARs with sufficient written narratives. We will provide a copy of the report to the senior official responsible for internal controls in the Department of the Air Force. DODIG

14 Finding Finding Air Force Officials Compliance With Past Performance Reporting Requirements Needs Improvement Air Force officials at four nonstatistically selected commands AFLCMC, HQ SMC, ACC AMIC, and 338th SCONS did not consistently comply with requirements for evaluating contractor past performance when preparing 48 PARs. Specifically, HQ SMC and ACC AMIC assessors did not prepare 7 of 48 PARs within the 120 day timeframe required by a USD(AT&L) memorandum. 12 In addition, Air Force officials at all four commands prepared 37 of 48 PARs without sufficient written narratives to justify the ratings given, and 6 of the 37 PARs also did not have sufficient descriptions of the contract purpose. These conditions occurred because: Air Force command-specific procedures did not consistently ensure timeliness or did not address timeliness; assessors did not understand PAR rating definitions or evaluation factors; assessors did not take, or properly implement, training; or Air Force officials did not consistently perform adequate reviews of the written narrative. AFLCMC, HQ SMC, and 338th SCONS did not have written procedures to register contracts; however, Air Force officials properly registered or had a valid reason for not registering all 161 contracts 13 in CPARS. Written procedures are necessary to ensure continued compliance with registration requirements. As a result, Federal source selection officials did not have access to timely, accurate, and complete contractor performance assessment information needed to make informed decisions related to contract awards or other acquisition matters USD(AT&L) memorandum, Past Performance Assessment Reporting, January 9, For details on the late PARs and number of days late, see Table 2. The four commands awarded a total of 161 contracts valued at $5.4 billion. We determined that assessors completed PARs for 58 of the 161 contracts, as of September 2, We reviewed 48 of the 58 PARs. 6 DODIG

15 Finding HQ SMC and ACC AMIC Assessors Prepared PARs Late, and Some Commands Did Not Have Procedures to Ensure Timeliness HQ SMC and ACC AMIC assessors did not prepare 7 of PARs within the 120 day requirement and prepared the 7 PARs an average of 65 days late. See Appendix C for a summary of the PARs reviewed and the number of days late for each of the seven PARs. Table 2 identifies the number of late PARs and the average number of days they were late at the two commands. Table 2. Number and Average Days of Late PARs Command Number of Late PARs Average Days Late HQ SMC 3 88 ACC AMIC 4 47 Total 7 65* * The total average days late is the weighted average of only the seven late PARs and their average days late at the two commands. Generally, assessors prepared PARs late because their command did not have written procedures to ensure timeliness of PARs or the written procedures were ineffective. The FAR 15 states that agencies must perform frequent evaluation of compliance with reporting requirements so they can readily identify delinquent past performance efforts. The FAR 16 also requires officials to prepare PARs at least annually and at the time the contractor completes the work. The USD(AT&L) memorandum 17 requires officials to complete PARs within 120 days of the end of the evaluation period. In addition, guidance for CPARS 18 states that the contracting or requiring office should establish procedures to implement CPARS, including monitoring the timely completion of reports. Furthermore, the contractor has 60 days to respond to the PAR. Although the commands tracked the status of PARs, HQ SMC and ACC AMIC assessors still prepared PARs late From the universe of 161 contracts, 58 had completed PARs as of September 2, We reviewed a nonstatistical sample of 48 of 58 PARs. See Appendix A for a complete discussion of our scope. FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Procedures, (e). FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contractor Performance Information, , Policy, (a), General. USD(AT&L) memorandum, Past Performance Assessment Reporting, January 9, Guidance for the Contractor Performance Assessment Reporting System (CPARS), July DODIG

16 Finding ACC AMIC had some procedures to ensure timeliness. The ACC AMIC Guide for CPARS Reporting states that the program manager or contracting officer s representative has 45 days to write the PAR and send it to the contracting officer for review and validation before the contracting officer sends the PAR to the contractor. However, the procedures do not provide a timeframe for the contracting officer to review and validate the PAR before it is sent to the contractor. For example, an ACC AMIC assessor completed two PARs 5 and 36 days late. The assessor stated that before he could prepare the PAR, the incentive board 19 needed to determine the incentive fee to award the contractor. The FAR 20 requires assessors to evaluate incentive fees in the PAR; therefore, the assessor could not submit the PAR until the board determined the incentive fee. The Director of ACC AMIC issued a memorandum 21 on October 15, 2015, which provides specific timeliness procedures to ensure assessors prepare PARs within the 120 day requirement. The Director of ACC AMIC should monitor compliance with the revised procedures to ensure assessors prepare PARs that meet the 120-day requirement in the USD(AT&L) memorandum. HQ SMC and 338th SCONS did not have procedures to ensure timeliness. Two divisions within AFLCMC had written procedures to ensure timeliness, but the overall command did not have procedures to ensure timeliness. Although 338th SCONS and AFLCMC did not prepare PARs late, as stated in the Standards for Internal Control in...documentation the Federal Government, 22 documentation is a necessary is a necessary part of an part of an effective internal control system. Furthermore, effective internal written procedures are needed to ensure continued control system. future compliance with timeliness requirements. The Commanders of AFLCMC, HQ SMC, and 338th SCONS should develop and implement command-wide written procedures that require assessors to prepare PARs that meet the 120 day requirement in the USD(AT&L) memorandum and build in the 60 days for the contractor s response The team of individuals who determine the incentive fee to pay the contractor, based on the contractor s performance. FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Procedures, (c)(1). Director of ACC AMIC, Contractor Performance Assessment Report System (CPARS) Roles and Responsibilities, October 15, Government Accountability Office Guide GAO G, Standards for Internal Control in the Federal Government, September 2014, section OV4.08, states that documentation is a necessary part of an effective internal control system. 8 DODIG

17 Finding Assessors Did Not Adequately Justify PAR Ratings Air Force assessors at the four commands did not justify the ratings given for 37 of 48 PARs with sufficient written narratives, as required by the FAR. In addition, HQ SMC, ACC AMIC, and 338th SCONS assessors did not prepare clear descriptions of the purpose of the contract for 6 of 37 PARs, as required by the FAR. The FAR 23 states: The evaluation should include a clear, non-technical description of the principal purpose of the contract or order. The evaluation should reflect how the contractor performed. The evaluation should include clear relevant information that accurately depicts the contractor s performance, and be based on objective facts supported by program and contract or order performance data. It is important that the assessor submits a rating consistent with the definitions and that thoroughly describes the rationale for a rating. See Appendix C for a complete summary of the PARs we reviewed. See Appendix D for a summary of the specific evaluation factors that assessors did not support. Table 3 identifies the number of PARs without written narratives to support the ratings given at each of the commands we visited. It is important that the assessor submits a rating consistent with the definitions and that thoroughly describes the rationale for a rating. Table 3. Summary of Evaluation Factors With Insufficient Written Narratives Command Number of PARs Reviewed PARs With Insufficient Written Narratives AFLCMC 10 5 HQ SMC 9 8 ACC AMIC th SCONS Total Table 42 1 in the FAR 24 defines each rating definition and describes what the assessor needs to include in the written narrative to justify the rating. See Appendix E for FAR Table FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Procedures, (b)(1). FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Procedures, Table 42-1, Evaluation Rating Definition. DODIG

18 Finding According to the FAR, a very good rating means that the contractor met the contract requirements, exceeded some of the contract requirements to the Government s benefit, and effectively corrected minor problems. The FAR further states that, to justify a very good rating, the assessor should identify a significant event and state how it was a benefit to the Government. For example, an ACC AMIC assessor rated a contractor very good for the management evaluation factor on a PAR. The written narrative stated: The one exception to the contractor s reasonable and cooperative behavior was the ISSO [Information System Security Officer] who was argumentative when dealing with outside agencies, leading to problems to coordination for the unit and delays in accomplishing tasks that required outside coordination. The narrative did not describe how the contractor met contractual requirements or a significant event that was a benefit to the Government; therefore, the narrative did not justify the very good rating. According to the FAR, an exceptional rating means that the contractor met contract requirements, exceeded many of the contract requirements to the Government s benefit, and effectively corrected minor problems. The FAR further states that, to justify an exceptional rating, the assessor should identify multiple significant events or a singular event of sufficient magnitude and state how they were a benefit to the Government. For example, a 338th SCONS assessor rated a contractor exceptional for four evaluation factors quality, schedule, management, and regulatory compliance but the assessor wrote just one sentence for each evaluation factor that stated that the contractor complied with requirements or performed exceptionally. The assessor did not describe multiple events or a singular event of sufficient magnitude that were a benefit to the Government; therefore, the narratives did not justify the exceptional ratings. In addition to the narratives, it is important for assessors to prepare clear descriptions of the purpose of the contract for use by source selection officials. Table 4 demonstrates that PARs at three of the commands we visited had inadequate contract purpose descriptions. Table 4. Insufficient Description of the Contract Purpose Command Number of PARs Reviewed Insufficient Contract Purpose ACC AMIC 14 3 HQ SMC 9 1 AFLCMC th SCONS 15 2 Total DODIG

19 Finding For example, at 338th SCONS, one description of the contract purpose stated, Support AFSAT [Air Force Security Assistance Squadron] training program managers. This description did not provide a clear understanding of the principal purpose of the contract. Alternatively, a sufficient contract purpose description for an AFLCMC PAR stated: This effort provides a full range of U-2 weapon system program and support management, acquisition and oversight, program security, integrated logistics, associated support systems and equipment. The contractor performs research, development, test, and evaluation, initial integration, and all other task utilizing programmed funds. Included in this effort are (1) spares, (2) bonded stock spares to support depot overhauls, (3) scheduled overhauls and unscheduled repairs, (4) engineering support, (5) technical data sustainment, and (6) program depot maintenance (PDM). This description provides source selection officials with a clear understanding of the purpose of the contract. As the CPARS guidance 25 states, the value of a PAR to a future source selection team is directly linked to the care taken to prepare a quality and detailed narrative that accurately reflects the contractor s performance on the contract. Generally, assessors did not provide sufficient written narratives to justify the rating given. Also, assessors did not prepare clear descriptions of the purpose of the contract. These conditions occurred because: Generally, assessors did not provide sufficient written narratives to justify the rating given. assessors did not understand PAR rating definitions or evaluation factors, assessors did not take training or periodic refresher training or did not properly implement training when they did take it, or Air Force officials did not consistently perform adequate reviews of the written narratives. Assessors Gave Ratings Higher Than They Could Support and Did Not Rate Required Evaluation Factors Assessors gave ratings that were higher than they could support or assessors rated required evaluation factors as not applicable. See Appendix E for the CPARS rating definitions. 25 Guidance for the Contractor Performance Assessment Reporting System (CPARS), July DODIG

20 Finding Assessors Gave Ratings Higher Than They Could Support Assessors did not provide sufficient written narratives to support ratings for 98 evaluation factors on 37 PARs. Specifically, for: One PAR, an assessor for ACC AMIC rated the contractor as satisfactory in two evaluation factors; however, the written narrative for each evaluation factor did not describe how performance met contractual requirements without any significant weaknesses, which the FAR requires to justify a satisfactory rating. 17 PARs, assessors for all four commands rated contractors as very good in 34 evaluation factors; however, the written narrative for each evaluation factor did not provide an example of a significant event that exceeded contractual requirements and benefitted the government, which the FAR requires to justify a very good rating. 24 PARs, assessors for all four commands rated contractors as exceptional in 62 evaluation factors; however, the written narratives did not provide examples of multiple significant events or a singular event of sufficient magnitude that exceeded contractual requirements and benefitted the government, which the FAR requires to justify an exceptional rating. For example, an assessor at ACC AMIC rated a contractor as exceptional for the quality evaluation factor without describing multiple significant events or a singular event of sufficient magnitude that were a benefit to the Government. The assessor stated that he did not support the rating because he generalized important information. Also, he did not provide evidence that he took Quality and Narrative Writing training. Therefore, he did not understand the amount of support he needed to include in the PAR narrative to justify an exceptional rating. Also, assessors for 14 PARs provided examples and Assessors explanations that, if written in the narrative, would indicated they have been sufficient to justify the ratings given for did not understand 26 evaluation factors. However, the assessors did not the rating definitions or incorrectly stated include the information in the written narrative because that an evaluation they did not understand the level of detail required to factor was not justify the ratings. Assessors indicated they did not applicable. understand the rating definitions or incorrectly stated that an evaluation factor was not applicable. 12 DODIG

21 Finding Required Evaluation Factors Not Rated Assessors at all four commands did not rate 27 required evaluation factors. The FAR 26 requires assessors to evaluate the contractor s performance on the following: Technical (quality of product or service), Cost control, Schedule and timeliness, Management or business relations, and Small business subcontracting. In addition, CPARS guidance 27 states that assessors will assess compliance with all terms and conditions in the contract relating to applicable regulations and codes under the regulatory compliance evaluation factor. An ACC AMIC assessor stated that she did not think she had to rate the schedule evaluation factor because the contract did not have a delivery schedule. However, under another evaluation factor, the ACC AMIC assessor stated that the contractor delivered trip reports and other mandated information within the contractually mandated timeframe. This information directly related to the schedule evaluation factor. In another example, an HQ SMC assessor stated that he did not complete the regulatory compliance evaluation factor because the contract did not contain clauses related to regulatory compliance. However, the contract contained clauses including anti-kickback procedures, security requirements, drug-free workplace, and prompt payment; therefore, the assessor should have rated the regulatory compliance evaluation factor. Because assessors did not understand the rating definitions or required evaluation factors, the Commanders of AFLCMC, HQ SMC, and 338th SCONS and the Director of ACC AMIC should train assessors on the PAR evaluation factors and PAR rating definitions, as outlined in the FAR and CPARS guidance FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Procedures, (b)(2). Guidance for the Contractor Performance Assessment Reporting System (CPARS), July DODIG

22 Finding Assessors Did Not Take or Properly Implement CPARS Training Air Force assessors did not consistently take Quality and Narrative Writing training, which CPARS guidance 28 identifies as a best practice, or did not take periodic refresher training. Specifically, assessors for: 30 PARs did not take Quality and Narrative Writing training and did not prepare sufficient written narratives to justify the ratings given; 29 and 5 PARs took Quality and Narrative Writing training, but still did not prepare sufficient written narratives to justify the ratings given. Assessors need training to fully understand the role of PARs in source selection decisions and how to write detailed narratives. The FAR 30 requires source selection officials to evaluate past Assessors need training performance in making award decisions. According to to fully understand CPARS Guidance 31 it is imperative that PARs include the role of PARs detailed, quality-written information. Although in source selection Air Force memoranda 32 require officials with roles in decisions and how to write detailed CPARS to take CPARS training within 30 days of role narratives. appointment, the memoranda do not specifically require officials to take Quality and Narrative Writing training. The Quality and Narrative Writing training for CPARS addresses the purpose of a PAR and the level of detail necessary to justify and describe the contractor s performance. AFLCMC, HQ SMC, ACC AMIC, and 338th SCONS officials did not require assessors to take Quality and Narrative Writing training for CPARS. Some assessors took the training, but did not properly implement it. The Director of ACC AMIC issued a memorandum 33 on October 15, 2015, that requires assessors and reviewers to take Quality and Narrative Writing training and assessors to take periodic refresher training every 3 years. Therefore, the Commanders of AFLCMC, HQ SMC, and 338th SCONS should ensure assessors take initial and periodic refresher CPARS Quality and Narrative Writing Training and the Director of ACC AMIC should monitor compliance with the October 15, 2015, memorandum that requires assessors to take initial and periodic refresher Quality and Narrative Writing training Guidance for the Contractor Performance Assessment Reporting System (CPARS), July We were unable to determine whether ACC AMIC assessors who prepared two PARs took Quality and Narrative Writing training because they were on long-term leave and we could not interview them. FAR Part 15, Contracting by Negotiation, Subpart 15.3, Source Selection, , Evaluation Factors and Significant Subfactors. Guidance for the Contractor Performance Assessment Reporting System (CPARS), July Office of the Assistant Secretary of the Air Force for Acquisition memoranda, Past Performance Assessment Reporting (supersedes SAF/AQ Memorandum, Past Performance Assessment Reporting, dated 1 July 2009), March 4, 2012, and superseding memoranda dated September 3, 2014, and September 15, Director of ACC AMIC, Contractor Performance Assessment Report System (CPARS) Roles and Responsibilities, October 15, DODIG

23 Finding Air Force Officials Reviews of Written Narratives Did Not Consistently Identify Noncompliance With the FAR The reviews of written narratives performed by AFLCMC, HQ SMC, and ACC AMIC officials did not identify noncompliance with the FAR. 34 Specifically, the reviews did not identify 71 evaluation factors for which the assessor did not support the rating given. Also, the reviews did not identify four contract effort descriptions that did not provide source selection officials with a clear understanding of the purpose of the contract. The Standards for Internal Control in the Federal Government 35 state that documentation is a necessary part of an effective internal control system. Written procedures ensure uniformity of PARs; however, commands had inconsistent procedures for reviewing the written narratives. AFLCMC had written procedures for two divisions and unwritten procedures overall, but no command-wide written procedures. HQ SMC written procedures required a management review, but did not include details regarding the reviews. ACC AMIC had command-wide written procedures. 338th SCONS did not have procedures. At AFLCMC, we identified best practices to ensure written narratives complied with FAR rating definitions. Although AFLCMC did not have command-wide written procedures, the U 2 branch of the At Command and Control, Intelligence, Surveillance, and AFLCMC, Reconnaissance (C2ISR) division and the Medium Altitude we identified Unmanned Aircraft Surveillance (MA UAS) division best practices to ensure written within AFLCMC had written procedures for preparing narratives complied and reviewing PARs. In addition, the CPARS Focal Point with FAR rating at AFLCMC C2ISR ensured assessors coordinated the PAR definitions. with personnel from the program office, contracting office, and other functional areas, and documented their review using a PAR coordination sheet. AFLCMC MA UAS officials used a quality rating matrix to support each evaluation factor in the PAR narrative. Although ACC AMIC had command-wide procedures to review written narratives, the reviews performed by ACC AMIC officials did not identify 33 evaluation factors for which the written narrative did not support the rating given, and three contract FAR Part 42, Contract Administration and Audit Services, Subpart 42.15, Contract Performance Information, , Procedures, (b)(1). Government Accountability Office Guide GAO G, Standards for Internal Control in the Federal Government, September 2014, section OV4.08, states that documentation is a necessary part of an effective internal control system. DODIG

24 Finding effort descriptions that did not clearly describe the purpose of the contract. Therefore, the review procedures at ACC AMIC were not consistently effective. The Director of ACC AMIC should improve procedures for reviewing the written narratives and monitor compliance with those procedures. AFLCMC, HQ SMC, and 338th SCONS did not have command-wide descriptive written procedures to review written narratives. The Commanders of AFLCMC, HQ SMC, and 338th SCONS should establish command-wide written procedures for reviewing PARs and monitor reviews of the written narratives to verify compliance. Assessors Complied With Registration Requirements, but Written Procedures Needed Air Force officials properly registered or had a valid reason for not registering contracts, in accordance with CPARS Guidance. 37 Specifically, officials registered 60 contracts and did not register: 89 contracts or orders because they were indefinite-delivery type, 9 contracts because they were consolidated in the PAR for 1 contract, 1 contract because it was transferred to a different Air Force command, and 2 contracts because they were cancelled. CPARS Guidance requires officials to register all contracts that meet the reporting thresholds, as previously discussed. CPARS Guidance also allows officials to choose how they register indefinite-delivery contracts and the orders awarded against them. Officials may choose to register the base contract or the orders. The assessors provided valid rationales for not registering the remaining contracts. Although Air Force officials complied with CPARS Guidance, AFLCMC, HQ SMC, and 338th SCONS did not have written procedures to register contracts. Written procedures are needed to ensure continued compliance with registration requirements. Furthermore, CPARS Guidance states, the contracting or requiring office should: establish procedures to implement CPARS across the organization. Therefore, Commanders at AFLCMC, HQ SMC, and 338th SCONS should develop and implement written procedures to register contracts Registering the contracts enables the assessor to write PARs in CPARS. Guidance for the Contractor Performance Assessment Reporting System (CPARS), July DODIG

25 Finding Air Force Officials Did Not Adequately Justify Past Performance With Readily Available Information As a result of Air Force officials not complying with requirements for completing PARs, Federal source selection officials did not have access to timely, accurate, and complete contractor performance assessment information needed to make informed decisions related to contract...federal awards or other acquisition matters. The FAR 38 source selection states that a satisfactory performance record is an officials did not have indication of a responsible contractor. In addition, access to timely, accurate, the FAR 39 states that officials must evaluate and complete contractor past performance in all source selections for performance assessment information needed to make negotiated competitive acquisitions expected to informed decisions related exceed the simplified acquisition threshold unless to contract awards or the contracting officer documents the reason other acquisition past performance is not an appropriate evaluation matters. factor for the acquisition. Because source selection officials are required to evaluate past performance in making award decisions, it is imperative for PARs to include detailed, quality written information. Each PAR should effectively communicate contractor strengths and weaknesses to source selection officials. Also, the contract effort description is of critical importance because it assists source selection officials in determining the relevance of the program or project to their source selection. ACC AMIC Management Actions Taken The Director, ACC AMIC, issued a memorandum 40 on October 15, 2015, that requires personnel with assessor and reviewer roles in CPARS to complete Quality and Narrative Writing training within four weeks of assignment to CPARS and assessors to take refresher training every 3 years. Furthermore, the memorandum provides specific timelines for each role and stage in the preparation process of a PAR and builds in the 60 days for the contractor s response. For example, the memorandum states that the assessor should prepare the PAR within 20 days of the end of the contract period of performance and have it reviewed within 40 days of the end of the contract period of performance FAR Part 9, Contractor Qualifications, Subpart 9.1, Responsible Prospective Contractors, , General Standards. FAR Part 15, Contracting by Negotiation, Subpart 15.3, Source Selection, , Evaluation Factors and Significant Subfactors. Director of ACC AMIC, Contractor Performance Assessment Report System (CPARS) Roles and Responsibilities, October 15, DODIG

26 Finding Management Comments on the Findings and Our Response 338th Specialized Contracting Squadron Comments The Commander, 338th SCONS, agreed with the report statement that 338th SCONS assessors did not prepare clear descriptions of the purpose of the contract for 6 of 37 PARs, as required by the FAR. The Commander stated that 338th SCONS personnel will enforce training requirements for assessors and maintain a database of completed training. The Commander disagreed with our determination that the contract effort description, Support AFSAT [Air Force Security Assistance Squadron] training program managers was not sufficient. The Commander stated that the clarity of the description is subjective and that the report compares advisory and assistance services to a weapons system program. The Commander further stated that, for a nonsystems contracting activity, the assessor provided a concise description of the program s purpose. Our Response The Commander stated that the contract was for advisory and assistance services. However, the contract purpose description only states support not advisory and assistance services. That the support was for advisory and assistance services was a detail that 338th SCONS officials should have included in the contract purpose description. In addition, the contract purpose description is unclear as to whether the contractor is supporting or training program managers. Also, the CPARS Quality and Narrative Writing training uses a similar example as a contract purpose description that is not sufficient. The example used in the training is: The contractor provides maintenance and support of VFED 41 for the General Services Administration. The training specifically states that this description is not sufficient because it is missing: detail of scope, complexity of contract, key technologies, and definitions of acronyms and technical terms. The 338th SCONS description of the contract purpose lacks similar items, such as scope detail and contract complexity. Therefore, the contract purpose description was not sufficient. 41 This is an acronym made up for training purposes to demonstrate that acronyms should be defined in the contract effort description. 18 DODIG

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